Thomas R. Fox (tfox@tfoxlaw.com) is the Compliance Evangelist.
In November, the Justice Department premiered a new policy, the FCPA Corporate Enforcement Policy, regarding Foreign Corrupt Practices Act (FCPA) enforcement.[1] Deputy Attorney General Rod Rosenstein, in a speech announcing the new policy, spoke eloquently about the economic costs of corruption and how robust FCPA enforcement benefits not only the United States and American companies, but also companies, peoples, and nations literally across the globe.[2] He also made clear that corporations, through compliance with the FCPA, are a part of this international effort.